| Comment Number: | EM-017573 |
| Received: | 3/10/2005 3:06:47 PM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| No Attachments |
Comments:
----- Below please find my comments concerning the proposed National Security Personnel System. Subpart C 9901.301-9901.373 Performance payouts; No criteria has been published pertaining to the behavior requirements to obtain bonuses/awards. Bonuses appear to be distributed at the discretion of the supervisor. This could potentially pit one employee against the other causing a disruption in the work environment where a majority of the employees' energy/efforts will be toward influencing the supervisor's evaluation rather than focusing on the mission. There are no objective standards published with this document which can be used by the employee to calculate how to achieve the performance necessary to attain the criteria to receive a bonus. Everything appears to be subjective as to what will appeal to the supervisor's personal interests. Subpart C 9901.301-9901.373 Setting and adjusting rates; Paybanding is too broad a spectrum to classify some job series. It will unfairly lump together jobs which should not be classified together and will unfairly put some employees at the lower end of the pay spectrum. Employees will be competing against other series for pay and evaluation. Instead of annual pay increases employees will get a pay increase equal to the percent the minimum rate their band was increased. Subpart G 9901.701-9901.721 Mandatory removal offenses; The proposed standard for taking an adverse action is "for such cause as will promote efficiency of the service"; this is extremely vague and could be potentially abused by supervisors. The criteria, as written, appears to be subjective rather than objective. There is no published guidelines that detail what the offenses are, and it appears they will be considered on a case-by-case basis. Subpart D 9901.401-9901.409 Performance behavior accountability; No guidelines or regulations are shown as to what constitutes poor behavior. How is behavior evaluated? Subjectively or objectively? This has the potential for extreme abuse by supervisors who would not have to show objective causes for disciplinary actions except that the employee's behavior was considered a threat to national security. Subpart D 9901.401-9901.409 Setting and communicating performance expectations; What guidelines/rules do supervisors have to evaluate performance? How do the employees know what the expectations of management are toward which they should tailor their behavior/work habits? This is too vague and has the potential to be abused by supervisors toward those they would show favoritism. Subpart I 9901.901-9901.928 Labor management relations; This appears to impact and negate any existing negotiated agreements. This shows bad faith bargaining on the part of DOD to honor existing agreements. Local bargaining units should be allowed to renegotiate contracts with their respective employers and take a more active role with management in executing the new personnel system. Subpart I 9901.901-9901.928 Management rights; By expanding the list of non-negotiable subjects the NSPS is effectively eliminating any input from the employees or their bargaining units, and DOD is not taking into consideration feedback from the workforce which will be so drastically impacted by this document. Conclusion: As a 20 year Civil Service employee I am deeply disturbed by the proposed changes that the National Security Personnel System would bring to the DOD workforce. Employee protection, seniority, bargaining rights, pay increases and basic human rights will be eliminated in favor of a system where performance evaluations are based on a subjective system of rules which will encourage favoritism and destroy employee moral. I do not feel that NSPS, as now written, is a fair or just system and I hope that the feedback I provide will be taken into consideration.